Contract analysis

I. Background Aurelius Media Americas Inc. ("AMA") has been a client of NovaPay Solutions since approximately January 1, 2019. AMA is a Delaware corporation qualified to do business in the State of California, with its principal office located at 8500 Sunset Boulevard, Suite 1400, West Hollywood, California 90069. AMA is a wholly owned subsidiary of Aurelius Global Media Group PLC, a United Kingdom-headquartered publ

II. Scope of Data Request The subpoena identifies five categories of data and documents to be produced by NovaPay. Set forth below is a detailed description of each category, together with additional context intended to assist NovaPay's data extraction team in identifying and producing the responsive records. We have endeavored to be as specific as possible in order to minimize ambiguity and reduce the need for follo

III. Requested Format To facilitate efficient analysis of the produced data, we respectfully request that all data be produced in delimited text format — either comma-separated values (CSV) or tab-delimited format — suitable for import into a database analysis tool. We anticipate that the data will be analyzed using relational database software and statistical analysis tools, and delimited text files are the most ver

IV. Confidentiality We wish to advise NovaPay that a Stipulated Protective Order has been entered in this case. The Protective Order was submitted to the Court on approximately February 15, 2023, and governs the treatment of confidential information produced in connection with the litigation. The Protective Order establishes two tiers of confidentiality designation: "CONFIDENTIAL" and "HIGHLY CONFIDENTIAL — ATTORNEYS

V. Coordination with AMA We wish to confirm that this subpoena has been coordinated with AMA's in-house legal team, and that AMA consents to the production of the requested data by NovaPay. AMA understands the scope of the data request set forth herein and will authorize NovaPay to produce responsive records in accordance with any data release, consent, or authorization procedures that may be required under NovaPay's

VI. Timeline and Logistics We recognize that the data extraction and production process may require meaningful technical effort on the part of NovaPay's team, and we wish to work collaboratively with NovaPay to establish a realistic and mutually agreeable production timeline. Accordingly, we request that NovaPay provide an estimated timeline for data extraction and production upon receipt of this letter, including an

VII. Costs We acknowledge that NovaPay may incur costs in connection with the extraction, compilation, formatting, and production of the data requested in the subpoena. Such costs may include, without limitation, data engineering labor, database query development, quality assurance and validation, and administrative overhead associated with document compilation and production logistics. AMA has agreed to bear reasona